TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 14, 2019

In 2010, Congress amended Internal Revenue Code (IRC) sec. 6201 by adding subsection (a)(4), which authorizes the IRS to assess and collect the amount of criminal restitution ordered for failure to pay any tax in the same manner as if the restitution was a tax.  The assessment could be made at any time after all […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 29, 2019

We are pleased to announce that three of our principals will be speaking at the upcoming May Tax Section meeting in Washington, D.C. on May 9th through the 11th. Steven Toscher and Jonathan Kalinski will be speaking on Collection Based Tax Crimes. Over the last few years, the Internal Revenue Service Criminal Investigation Division and the Department of Justice […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 17, 2019

We are pleased to announce that STEVEN TOSCHER has been appointed to the Law360 Tax Authority Federal Editorial Advisory Board. The purpose of the editorial advisory board is to get feedback on Law360’s coverage and gain insight from experts in the field on how best to shape future coverage.

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 17, 2019

We are pleased to announce that Sandra Brown and Evan Davis will be teaching at an upcoming CAL STATE LA TAX AND ACCOUNTING SEMINAR: CURRENT DEVELOPMENTS IN IRS CRIMINAL TAX ENFORCEMENT,  Saturday, April 27, 2019, 8:30 a.m. For over 30 years Cal State LA’s Accounting and Tax Seminars have presented current, topical information for tax practitioners including CPAs, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 10, 2019

  Jonathan Kalinski concentrates his practice in complex civil tax litigation and criminal tax. Mr. Kalinski represents individuals, corporations, pass-through entities, trusts, and estates in all stages of state and federal tax disputes, including audits and examinations, administrative appeals, trials, and appellate litigation. He also specializes in disclosures of undeclared foreign accounts and assets. Mr. Kalinski represents businesses […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, April 06, 2019

We are pleased to announce that Steven Toscher and Michel Stein will be presenting at an upcoming STRAFFORD WEBINAR: NEW IRS SCRUTINY ON CRYPTOCURRENCY REPORTING: FILING REQUIREMENTS AND EXCHANGE TREATMENT.  Wednesday, June 5, 2019 from 10:00 a.m. – 11:30 p.m. (EDT)/1:30 p.m. to 2:30 p.m. PST.  For more information Click Here. The IRS announced concern over “massive” […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 24, 2019

We are pleased to announce that Robert Horwitz will be presenting at the upcoming ABA 2019 May Tax Meeting, Friday, May 10, 2019 from 4:45 p.m. to 5:45 p.m. (EST). Many penalties resulting from failing to report foreign income and assets are assessable (i.e., the deficiency procedures do not apply). This panel will discuss the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 22, 2019

For 34 years, the Annual Tax Controversy Institute has been among the preeminent tax conferences in the United States exclusively dedicated to tax controversy and tax litigation! This year, I was honored and privileged to serve as Chair of The Annual Tax Controversy Institute.  Please join us on October 22, 2019 for this year’s Tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 22, 2019

The explosion of virtual currency has created challenging tax reporting issues for taxpayers and tax professionals alike. But does this uncertainty mean the federal government will shy away from prosecuting criminal tax cases involving the failure to report virtual currency? The odds-on favorite answer is simply: no. Sandra R. Brown examines virtual currency and the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 17, 2019

The Internal Revenue Service has broad authority to examine books and records and interview witnesses for the purposes of determining the liability of any person for taxes, penalties or interest and collecting any liability.  This authority includes the power to issue summonses, including to third-parties.  Under Powell v United States, 379 U.S. 48 (1964), the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 08, 2019

While many people are familiar with the phrase “Cash is King,” dealing in cash can, and often does, take on new meaning when it comes to the IRS. There is, of course, the obvious obligation to ensure that any, and all, cash received as income is properly reported annually on the appropriate tax return. However, that […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, February 26, 2019

The United States Sentencing Commission  recently released a study of sentencing of federal offenders convicted of economic crimes.  The study included within the category of “economic crimes” thus sentenced under §2B1.1 of the United States Sentencing Guidelines (USSG), tax crimes and identity theft.  Tax crimes encompass Title 26 (Internal Revenue Code) violations, conspiracies to defraud […] Read More…